Course ID: IIT-L

Introduction to U.S. Taxation of International Transactions

A shrinking world caused by advances in technology and “globalization” of routine business transactions is creating the need for even relatively small accounting practices to become informed about international tax issues. Many tax rules will be established by treaty, and CPAs must know what those treaties contain and when they apply, especially when there is a conflict between a treaty and the Internal Revenue Code. US citizens working in other countries, foreign nationals working in the United States, cross-border transfers of equipment and technology, foreign sales and purchases, foreign investments and investors-all combine to require working knowledge of international tax issues. Participants will be introduced to a broad understanding of international tax planning and compliance that will assist them in advising clients and handling routine compliance without a hitch.


LEARNING OBJECTIVES
  • Recognize international tax issues
  • Find relevant tax provisions in Tax Treaties
  • Determine taxing jurisdiction for different types of income
  • Identify reporting differences and treaty provisions that apply to common transactions
  • Plan for maximum benefit from foreign tax credit
  • Accurately calculate taxable income of a U.S. Citizen working in another country
  • Accurately calculate taxable income (and tax) of a Foreign national working in the U.S.
  • Correctly apportion income of a multi-national business enterprise
  • Apply tax rules to determine “effectively connected” business operations
  • Anticipate and create tax savings opportunities

MAJOR TOPICS
  • Sourcing of income?
  • Section 911 – foreign source income and various per diems and allowances
  • Foreign tax credits
  • Foreign corporations
  • Withholding taxes
  • “Sub-part F” income
  • Transfer Pricing – IRC Sec. 482
  • Tax treaties
  • Taxation of foreign persons
  • Current Developments in U.S. taxation of foreign transactions

DESIGNED FOR
CPAs in public practice and key positions in industry

FIELD OF STUDY
Taxes

PREREQUISITES
None

COURSE PRODUCER
Loscalzo Associates

CPE CREDITS
8.0

LEVEL
Basic
 

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